DOING THE RIGHT THING SSE’s guide to good business ethics DOING THE RIGHT THING DOING THE RIGHT THING DOING BUSINESS ETHICALLY Contents

What is this guide for? DOING THE RIGHT THING FOREWORD FROM ALISTAIR PHILLIPS-DAVIES 3 This is a general guide which supports the adoption of the right values, attitudes and behaviours to DOING BUSINESS ETHICALLY INTRODUCTION FROM LIZ TANNER 5 contribute to an ethical business culture at SSE. UNDERSTANDING ETHICS RULES AND VALUES COMBINED 6 BEING GUIDED BY VALUES THE SSE SET 7 It is not intended to be a comprehensive compendium of laws, regulations, policies and rules. MAKING ETHICAL DECISIONS PRACTICAL STEPS 9 SPEAKING UP YOUR RIGHT/YOU’RE RIGHT 11 Who is this guide for? SPEAKING UP YOUR PROTECTION 12 The information within this guide applies to all SSE employees, as well as people employed by other organisations to work on SSE’s behalf. PART 1 – STAYING SAFE AND SECURE IF IT’S NOT SAFE, WE DON’T DO IT 13 – PUTTING SAFETY AND HEALTH FIRST 15 – SAFEGUARDING THE ENVIRONMENT 16 – BEING CYBER SECURE 17 “ Business ethics is the application of – MANAGING DATA AND INFORMATION 18 ethical values to business behaviour. Business ethics is relevant both to the conduct of individuals and to PART 2 – TRADING FAIRLY AND TRANSPARENTLY COMPETING IN THE RIGHT WAY 19 the conduct of the organisation as – MAINTAINING BUSINESS SEPARATION 21 a whole. It applies to any and all – ENSURING FAIR COMPETITION 22 aspects of business conduct, from – GUARDING AGAINST WHOLESALE ENERGY MARKET ABUSE 23 boardroom strategies and how – MEETING DISCLOSURE AND SHARE DEALING OBLIGATIONS 24 companies treat their employees – PREVENTING CORRUPTION AND FINANCIAL CRIME 25 and suppliers to sales techniques – PROCURING GOODS AND SERVICES RESPONSIBLY 26 and accounting practices. – AVOIDING CONFLICTS OF INTEREST 27

“All organisations need to demonstrate PART 3 – WORKING TOGETHER VALUING THE PEOPLE WE WORK WITH 29 why they are trustworthy in order to – HUMAN RIGHTS AND MODERN SLAVERY 31 operate effectively and sustainably. – INCLUSION AND DIVERSITY 32 Reputations are not solely based on – BULLYING, HARASSMENT AND DISCRIMINATION 33 the delivery of products and services, – PAYING THE LIVING WAGE 34 but on how an organisation values its stakeholders. Having a reputation for PART 4 – ENGAGING WITH STAKEHOLDERS BEING OPEN AND ACCOUNTABLE 35 acting with honesty and integrity not – PROVIDING ACCURATE INFORMATION 37 only differentiates an organisation, it – ENGAGING WITH POLITICIANS AND REGULATORS 38 makes it more successful.” – TALKING TO MEDIA AND COMMUNICATIONS 39 Institute of Business Ethics – ENSURING TRANSPARENCY 40 ibe.org.uk @IBEUK DOING BUSINESS ETHICALLY FOR OURSELVES 41 KNOWING WHO TO SPEAK TO KEY CONTACTS 42

1 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 2 Foreword: Doing the right thing - What it means to me A guide to ethical business conduct DOING THE RIGHT THING

DoingDOING the right THE thing WhatRIGHT it means THING to me Foreword from Alistair Phillips-Davies I believe very few of us would actively set out to do the wrong thing, either in The Institute of Business Ethics says that doing business ethically makes for betterour personal business. livesI agree. or in the workplace. But we are all at risk of making judgments that prove to be inconsistent with ethical conduct, not because we meant to, but That’sbecause because we didn’tSSE will think only succeedabout the if we consequence, are a company inor which didn’t people pay enough want attention toto invest;what fromwe were which being people told. want to buy; with which people want to partner; and for which people want to work. It’s clear that people are most likely to invest in,This buy guide from, partneris designed with or to work help for you.companies It outlines that do the business principles ethically. of ethical business conduct that everyone in SSE is expected to meet and explains what to do if you At SSE, our purpose is to provide energy needed today while building a better worldspot orof energysense somethingfor tomorrow. that Our isn’t vision right. is to be a leading energy company in a net-zero world. We will only fulfil our purpose and achieve our vision if we do businessAs individuals ethically. there are things we can do to help us make the right judgments. That’s why we have a set of rules we must follow. Some rules are simply the law; Thisother guide rules is for are every higher one of standards us working that on behalf SSE seeksof SSE toand meet. is designed When to help these rules are uscombined understand with how the rules, SSE regulations SET of values and standards we have – alongthe best the withchance SSE SETof conducting of our valuesbusiness – underpin practice how in wethe should most eachethical do ourand jobs responsible and each make way; sure and we being do responsible business ethically. means doing the right thing. It is in all of our interests that we have a healthy business culture. That means ensuringIf we do we that, have: we are more likely to meet the needs of our customers. And in turn, •that ameans purpose, we values have and more vision chance that are of respected success by as the a business. Company’s stakeholders; •For me,an opera doingting the environment right thing that can is inclusive, sometimes diverse mean and engaging; having the courage to speak •up whena cultur youe that know encourages something us all is as wrong. people Itworking can also on simplybehalf of be SSE about to your own high standardsmake a of positive personal difference conduct. for stakeholders; • a way of working in which values guide decisions and actions; and • a way of working in which attitudes and behaviours are consistent with high I alsostandards want to of assure conduct you and that doing SSE’s the right senior thing. leaders will always be available if you have concerns that something is not right. Seeking advice, raising concerns or Thisreporting guide summarises misconduct how will we not can be all heldsupport against a healthy you. business culture – and in doing so support our Company’s success for the long term. I would urge you to read this guide carefully and keep it in a safe place to refer to Alistairin the future.Phillips-Davies SSE Chief Executive

Alistair Phillips-Davies, Chief Executive

4 5

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Introduction from Liz Tanner Rules and values combined It’s in all of our interests for SSE to be, and to be and the people who depend on us at SSE to do Working ethically means every one of us who behalf, can be daunting; and the rules are often recognised by stakeholders as, a company that our job properly. works for SSE has to follow the rules – the laws subject to review and change. That’s why SSE’s operates ethically. As people working on behalf passed in the UK Parliament and the devolved i-Comply portal exists on ssenet. By bringing of SSE, it’s in our interests, too. We want to work This guide confirms the mandate we have to legislatures in the UK and the Oireachtas in together in one place key rules applying to for a fair and ethical company. challenge behaviours or actions that may be Ireland; the regulations put in place by SSE and its individual business units, i-Comply unethical. Safecall gives us an independent Regulators; and the higher standards and values is designed to provide practical help to ensure At its simplest, this means every one of us who first point of contact if we feel we cannot raise we set for ourselves as a sustainable company people to work ethically. works for SSE has to follow the rules and meet concerns about wrongdoing in our teams or committed to achieving long-term success that the standards and values we set for ourselves as with our manager. creates value for shareholders and society. SSE’s own policies a sustainable company committed to achieving Similarly, SSE’s Group policies are highlighted long-term success that creates value for At SSE we are for a better world of energy. And Knowing the rules where relevant within this document, with the shareholders and society. we all want a great place to work. That means The rules can be society-wide, such as UK full set of Group policies available on ssenet. doing business ethically. In summary, it’s about and Irish laws on business practices which As Board-approved statements of intent and The fact is, companies succeed or fail by human first, staying safe and secure; second, trading prevent, restrict or distort competition; they can principles in relation to matters of significance to behaviour on sites, behind desks, in informal fairly and transparently; third, working together; be energy sector-specific, such as legal and SSE’s stakeholder groups, they are designed to discussions and in meetings – behaviour and fourth engaging with stakeholders. regulatory separation of businesses within the help in decision-making and guide every one of that is reflected in the millions of actions, same company; and they can be company- us in SSE towards doing business ethically and conversations, emails, text and other messages I hope this guide helps you in the important specific, such as SSE’s commitments to higher achieving sustainable business outcomes. that go back and forth in large companies like work you do for SSE and for the wider energy standards reflected in the Company’s policies SSE. system on which people, organisations and on things ranging from safety and health to Asking for help businesses across the UK and Ireland depend. protecting people’s data and tackling climate In keeping with SSE’s Teamwork value, the Every one of our jobs involves judgement, and change. commitment to supporting and valuing our in the busy, constantly-changing environment in Liz Tanner colleagues and working together as a team in which we all now work, this guide is intended to SSE General Counsel Combining rules and values an open and honest way, the SSE team includes help us get those judgements right. This guide Those higher standards are underpinned by our subject-matter experts within specialist areas doesn’t contain the answer to everything; but it values – Safety, Service, Efficiency, Sustainability, who provide practical guidance and advice. paints a picture of how we should all go about Excellence and Teamwork. These values should our jobs. guide the attitudes (reflected in SSE’s Group These include Human Resources; Safety, Health policies) and behaviours (reflected in SSE’s and the Environment; and General Counsel It also explains what to do if we spot or sense employee rules) of every one of us working on (Legal Services, Markets Regulation and Group something that isn’t right. behalf of SSE every day. It is this combination of Compliance and Data Protection). values, policies and rules that together represent Seeking advice, raising concerns or reporting SSE’s framework for doing business ethically and Full details of where you can go to for help can evidence pointing to wrongdoing are the actions for maintaining a healthy business culture. be found at the end of this guide. of responsible people committed to doing the right thing by their colleagues, the Company Navigating the rules The breadth and depth of the laws, regulations and standards applying to a large company such as SSE, and to all of us who work on its

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SSE’S VALUES

Safety Service Efficiency If it’s not safe, We are a company We focus we don’t do it. that customers on what can rely on. matters.

Sustainability Excellence Teamwork We do things We continually We work together, responsibly to improve the way respect each add long-term we do things. other and make value. a difference.

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Using a “decision tree” and applying simple a “yes check” is an effective way to guide you towards doing the right thing.

START

Does the decision comply Speak to the Legal or STOP NO with the law and regulatory ? Regulation team. principles?

YES

Ask for advice from STOP NO Will everyone be safe? ? SSE’s SHE Team.

YES

Check against the policies on Is it in line with SSE’s the Document Library and the STOP NO policies and values? ? values set out in this guide.

YES

Details of our commitments to stakeholders can be found STOP NO Is it fair to stakeholders? ? in the Annual Report. If in doubt, talk to your manager.

YES

Would you stand by STOP NO your decision if it was ? Talk to your manager. made public?

PROCEED

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An essential feature of a company that aims to do If you speak up with a concern in good faith, someone who speaks up will be committing RESOURCES AVAILABLE business ethically is ensuring everyone can report it will be investigated by professional and a very serious breach of SSE’s rules and will be evidence of wrongdoing, malpractice or fraud in • Group Whistleblowing Policy experienced individuals in SSE who know treated accordingly. the workplace – and has the confidence to do so • Whistleblowing Procedure how important it is to deal with things in a with impunity and without fear of repercussion. - Speak Up confidential and discreet way. If you raise a concern, the first step is to make sure you receive prompt acknowledgement This can be summarised as LISTEN, ACT Contact Reports from people who prefer to remain and are thanked for raising the issue. and PROTECT: Internal anonymous are valid and will always be • LISTEN – creating a culture for employees • Email: [email protected] investigated as long as the information provided After initial investigations are completed, to speak up is enough to base an investigation on. a decision will be made on whether a full • ACT – responding when wrongdoing is External investigation is needed, co-ordinated by the reported • Phone: 0800 915 1571 (UK) It does help if you provide your name and Group Security and Investigations team. Where • PROTECT – supporting employees who do 1800 812 740 (Ireland) contact details when raising an issue, so possible, you will be kept informed although the right thing • Email: [email protected] any requests for clarification or additional it may not always be possible to disclose full • Online: www.safecall.co.uk/report information can be made and so you can be details of the investigation. We are committed to abiding by the rules – the kept up to date with how the investigation is laws, regulations and standards applying to all going. There are many potential outcomes of an of us who work in SSE. SSE’s values and the If you don’t feel able to challenge attitudes, investigation, such as changes in working SSE Group policies are designed to guide our behaviours or actions within your team or wider The process for protecting employees that practices and policies, disciplinary action, behaviours; and employee rules are designed to part of the organisation, or able to raise issues speak up is detailed within SSE’s Whistleblowing dismissal, or possibly no action. Where guide our attitudes. This should be enough to with specialists in departments in SSE such as Policy. Anyone – however senior in the possible, you will receive an explanation ensure everyone in SSE does business ethically. Human Resources or Legal Services, Safecall Company – who tries to intimidate or victimise of the outcome. gives you an independent first point of contact. But bad things can happen in good companies. As CIPD (formerly Chartered Institute for Safecall is part of a wider SSE policy on Speaking Personnel and Development) says, unethical Up (sometimes called ‘whistleblowing’) that is workplace behaviour can vary from minor intended to act as a safety net to highlight any transgressions to illegal activity – but are unethical conduct by people working for SSE and essentially actions that harm the legitimate ensure it is stamped out. interests of the organisation, its workforce, customers and wider society. As someone working on behalf of SSE it’s your right to speak up. And as someone working on That’s why the SSE plc Board gives every behalf of SSE you’re also right to speak up when employee a mandate to challenge attitudes, you think you have grounds for doing so. That’s behaviours or actions that may fall short of what’s because you could be preventing significant expected by the laws, regulations and standards harm to people, the environment, the Company that apply to the Company. or wider society. It’s also because you’re supporting an ethical business culture that’s in This could include putting people in harm’s way the interests of the overwhelming majority of and at risk of injury; criminal offences; other colleagues in SSE and of the many stakeholders breaches of laws or regulations; actual or possible who depend on us at SSE to do a good job. That harm to the environment; abuse of Company means doing it ethically. property; abuse of position by managers; or harassment or bullying by colleagues.

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If it’s not safe, we don’t do it Safe means being protected from or not exposed to danger; and it also means being not likely to be harmed or lost. And at SSE, if it’s not safe, we don’t do it. That’s why we do everything we can to make sure no harm is done to people’s health and wellbeing or to the environment as a result of the work we do. It’s also why we do everything we can to safeguard people’s privacy, devices, programmes, systems and networks.

Part 1 covers: • Putting safety and health first • Safeguarding the environment • Being cyber secure • Managing data and information

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If it’s not safe, we don’t do it Protect, restore and enhance What is safety and health? This means supporting procedures, completing What is safeguarding the environment? We also seek to go above and beyond this and Safety at work isn’t only about single, injurious all relevant training and reporting safety hazards As a large energy company, the breadth and meet additional relevant voluntary standards incidents; or failure to maintain the integrity of or unsafe working practices. depth of SSE’s activities means many people’s in order to bring about positive environmental operational plant and equipment. It’s about the jobs involve interacting with the environment. At outcomes, such as working towards ‘biodiversity impact of work on occupational health and DILEMMA SSE, our aim is to identify and mitigate material net gain’ for new major projects after 2025. wellbeing. This ranges from the physical impact negative impacts on the environment, manage of repetitive activities not being carried out On site, there was a near-miss when an environmental risks and engage positively with DILEMMA appropriately to work giving rise to mental health employee tripped over an unmarked step stakeholders to improve the environmental issues – or mental health issues affecting our and fell without injury. Do I really have to impact of our business activities. We want to I have been asked to start a task before ability to do our job. report a safety incident even if nobody protect, restore and enhance the environment. all the environmental protection controls was hurt? set out in the project method statement Why is it important for business ethics? Why is this important for business ethics? have been put in place. What should I do? At SSE, if it’s not safe, we don’t do it. This is our This is a near-miss incident and reporting Good quality natural environments are not Safety Licence. these incidents is a very important way just essential for SSE to operate successfully, Environmental controls, such as surveys of identifying problem areas and can but also for society as a whole. SSE’s activities for protected species, silt settlement The people we work with are not simply our highlight some of the less obvious hazards can have impacts on environmental resources ponds, drip trays, spill kits, and waste colleagues. They are also partners, parents, in a workplace, or identify areas where a and services that provide value directly and storage containers are there to protect the children, sisters, brothers and friends. If someone problem is developing. For every accident, indirectly to others, so these impacts must be environment, and are a necessary part of is hurt working for SSE, or by someone working it’s estimated there are approximately 90 actively managed. SSE’s activities are subject many jobs. If these controls have not been for SSE, the consequences extend to that near-misses. With a good reporting system to a number of environmental regulations provided then use your Safety Licence person’s colleagues, family and friends. It’s in place, the hazard could be dealt with and it works constructively with a range of to stop, speak to your supervisor, and do fundamentally important that we all get home before someone is injured. environmental regulators to ensure that it not start until the required environmental safe from our work. meets the high standards of environmental controls are in place. performance and disclosure required. What are the right behaviours? RESOURCES AVAILABLE If it’s not safe, we don’t do it is not a slogan: it’s a What are the right behaviours? RESOURCES AVAILABLE licence for every person working on behalf of SSE • Group Safety and Health Policy In order to protect the environment and to insist on safe working for themselves and for operate in a sustainable way, we design, • SSE’s internal safety website, • Group Environment Policy the people around them. safetynet construct, operate and decommission our assets and conduct our operational activity in full • Group Environment Strategy

And to ensure we all get home safe we: Contact compliance with all relevant legal and regulatory • Take care of ourselves and each other; obligations – and go further if we can. Contact • All significant safety incidents must • All significant environmental • Take pride in our work and workplace; be reported within 30 minutes to • Plan, scan and adapt; We aim to decrease the impact of our resource incidents must be reported within the Employee Emergency line: 30 minutes to the Employee • See it, sort it, report it. 0800 107 3207 (UK) or 1 800 927 consumption by minimising resource use and waste production; engaging with the circular Emergency line: 0800 107 3207 219 (Ireland). The number is printed (UK) or 1 800 927 219 (Ireland). All employees of SSE are entitled to expect, and on the reverse of your SSE ID economy by using reprocessed materials and are expected to support, a working environment ensuring our waste can readily be reused or • The number is printed on the badge. reverse of your SSE ID badge. in which physical and mental health issues are • Email: [email protected] recycled as far as is practical and using materials recognised and understood and where practical that have sustainable lifecycle impacts. steps are taken to ensure those issues are resolved in a professional and sympathetic way.

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Be aware, take care, stay secure Look after people’s privacy What is cyber security? What is managing data and information? DILEMMA DILEMMA We live in challenging times. The threat of cyber- GDPR has become one of the best known crime has never been greater, and the risks we face I need to do some work on some SSE acronyms at work and beyond. It stands for I attended an energy conference and – at home and at work – are significant. Threats data that I have, and I’ve found a website General Data Protection Regulation and in received a number of business cards. Is to cyber security can take many forms, including which offers free software that can easily summary, it means it’s our job to keep people’s it OK to use this data to add to a list of phishing scams, hacking and taking control of do it. Is it OK to use it? data accurate, safe, secure, accessible to possible business opportunities under physical assets. authorised people only and lawful so that our GDPR? ‘Free’ software and services are often not details, those of our colleagues and other Why is this important for business ethics? licenced to be used by businesses, so this business stakeholders are properly protected. We If you receive a person’s business card The growing risk of cyber security means we may be illegal. Free software is often used observe the confidentiality of business units and it is unlikely they would expect to be have to be vigilant. At SSE, we are responsible for to disguise computer viruses which, if adhere to business separation through restriction put on a marketing database to receive nationally-important infrastructure in the UK and downloaded could then affect the whole of access to information. ongoing marketing material. However, Ireland, and that responsibility means making sure of SSE. Even if this is not the case, we if you receive a business card and ask our systems, assets and people are safe and secure, wouldn’t have any contract in place, or any Why is this important for business ethics? that person if they can be added to your and that customers are not put at risk. To ensure idea what the website or software will do SSE must be a company that people can trust. marketing database, this would likely be we do this we have our Be Aware, Take Care, Stay with the data or whether it will be stored Looking after people’s privacy is part of a wider, ‘clear and specific consent’. Secure approach: securely or shared with others. For these responsible approach to managing information • Being aware means being vigilant at all times, reasons you should only use software to make sure that we govern the creation, use, in different places and situations; that is approved by IT. It is better to talk storage and destruction of digital and physical RESOURCES AVAILABLE • Taking care means knowing what we must do to IT to see if SSE already has software information in all its forms (documents, records, with SSE information to keep it secure; and that can help, or to arrange purchase of a content). • Group Data and Information Policy • Staying secure means the actions we take corporate licenced version of the software. which will keep us and SSE cyber secure. What are the right behaviours? • GDPR e-learning module Personal data must be processed in a lawful, What are the right behaviours? fair and transparent way; collected for Contact RESOURCES AVAILABLE All SSE colleagues have an individual responsibility specified, explicit and legitimate purposes; and • Data protection incidents should be be reported through the SSE IT to work in a way that protects us all from cyber • Group Cyber Security Policy be adequate, relevant and limited to what is Service Centre Portal. Data handling threats. It is our duty to understand the risks, learn • Cyber security e-learning module necessary. guidance can be found on the how to recognise something unusual and take Data Protection Centre on ssenet all the steps we can to keep ourselves and our Contact In addition, personal data must be accurate including detail of Data Protection information and systems secure. • All Cyber Security Incidents should and where necessary kept up to date; kept for Specialists within each business be reported under the 30 minute no longer than necessary; and processed in area. For example, we might be tempted to ignore a rule by calling 0800 107 3207 secure ways that guard against accidental loss, suspicious looking email, but if the same email (ROI – 1 800 927 219). Further destruction or damage. was sent to another of our colleagues they may guidance can be found on the not spot the clues and open it. This is why it is Cyber Secure pages on ssenet and important to always report and not ignore anything at [email protected]. suspicious. • Suspicious emails should be reported via phishing button There are simple steps we must all take with our within Outlook. passwords, IT equipment and documents. See IT’s Be Aware, Take Care, Stay Secure document on ssenet and keep your cyber security e-learning up to date.

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Competing in the right way At SSE we are committed to trading fairly, to ensuring that we all know what constitutes a fair trade and what does not, and to speaking up when we suspect misconduct. Trading unfairly is not only unethical; it is illegal.

Part 2 covers: • Business separation • Ensuring fair competition • Guarding against wholesale energy market abuse • Meeting disclosure and share dealing obligations • Preventing corruption and financial crime • Procuring goods and services repsponsibly • Avoiding conflicts of interest

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Different businesses, same high standards Eliminating anti-competitive behaviour What is business separation? What is fair competition? DILEMMA SSE is a UK-listed company that comprises DILEMMA Successful economies depend on fair a number of subsidiary Business Units and competition, and successful companies I work in networks and I have been I have never had competition law training companies. Some of these subsidiaries are required do too. In SSE, our businesses depend on working on a quote for connecting a and have been asked to attend a meeting to be legally separate from other subsidiaries. well-functioning competition, where companies proposed wind farm being developed at Energy UK where there will be a number This requirement is called ‘business separation’. operate on a level playing field to ensure our by SSE Renewables. We are nearly ready of SSE’s competitors in attendance. Can customers and we are not unfairly disadvantaged. to provide a quote and I saw on Yammer I go? Why is this important for business ethics? a heated debate about how long it takes At SSE, we must not restrict or distort competition Why is this important for business ethics? to connect new wind farms. Can I reassure No. You must have a detailed in the energy market. SSEN Distribution, SSEN SSE’s continued success relies on ensuring the my SSE Renewables colleagues by understanding of your obligations under Transmission and SSE’s Independent Distribution trust of its customers, employees, shareholders, telling them that it won’t be long for competition laws before you have Network Operator, Forbury Assets Ltd, are therefore and partners. That requires us to take a this particular quote to be provided? meetings with SSE’s competitors. You need required, as part of their licences, to operate and responsible, transparent and honest attitude to understand what you cannot discuss and maintain legal and regulatory separation from other towards all those stakeholders. No. This is a perfect illustration of you also need to know what to do if one companies in the SSE Group. This includes not confidential information that networks holds of the other participants start discussing sharing any commercially sensitive information What is the legal position? because it is a monopoly business. There something that is against competition with other SSE Business Units, especially those Competition (also known as ‘antitrust’) laws exist must be no advantage to SSE Renewables rules. You should ask your line manager involved in generation and supply activities and to promote and safeguard competition and to that SSEN is owned by SSE. It would be to make sure you receive the competition any affiliate Independent Distribution Network deter and punish anti-competitive behaviour. very wrong for SSE Renewables to have law training before you attend a meeting Operator (see below). Competition laws combat illegal practices such information that one of their competitors like this. as price fixing, market sharing, bid rigging, and couldn’t have because they don’t have Rules around business separation also apply to prohibited behaviours that aim to abuse or access to SSE’s internal Yammer site. SSE’s Gas Storage business, which must also be maintain significant market power. Penalties for kept distinctly separate from other parts of the breaches of competition law apply to individuals RESOURCES AVAILABLE SSE Group; and the Regulation on Wholesale as well as companies. RESOURCES AVAILABLE • Group Corruption and Financial Crime Energy Market Integrity and Transparency (REMIT) Prevention Policy also has important implications for the how What are the right behaviours? • Risk Management and Internal • Competition law e-learning module information within SSE’s Business Units is In conducting its business, SSE has zero tolerance Control Policy managed (see page 24). in relation to any competition law infringement. • Group Procedures on Application of Contact We all have a responsibility to do our jobs in a Business Separation Rules • For guidance on competition What are the right behaviours? way that guards against any risk of breaching • Networks Business Separation law contact SSE’s Legal team at • Information about SSEN Transmission, SSEN competition law. Training in competition law is e-learning module [email protected] Distribution, SSE’s Independent Distribution • Business separation e-learning provided to any employee of SSE who needs it. Network Operator and SSE Gas Storage is module kept confidential within those businesses or the Corporate Services required to support Contact them; • Business Separation Compliance • No unfair advantage is provided by these Officer:[email protected] businesses to other parts of SSE; • SSE Networks Business Separation • Cross-subsidy between the businesses and team NetworksBusinessSepraration@ other parts of SSE is prevented; and sse.com • Use of the right branding; • Forbury Assets Compliance Officer • Similarly, all of the above apply to Forbury [email protected] Assets Ltd and SSE’s Gas Storage business.

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Maintain integrity What is REMIT? DILEMMA The Regulation on Wholesale Energy Market Transparency (REMIT) applies to wholesale My colleague and I have been working energy markets. It defines and prohibits market on a confidential project about the abuse (market manipulation, attempted market operation of a power station. We’re pretty manipulation or insider trading) and requires sure we don’t need to change any of the effective and timely disclosure of inside information about the power station on information by market participants. the REMIT portal. Are we OK to leave it at that? Why is this important for business ethics? REMIT is intended to ensure that energy No. Under our REMIT obligations we are customers and other stakeholders can have required to provide timely and accurate confidence that wholesale energy markets updates on any of our activities that could operate in an open and competitive way. have an impact on wholesale energy markets and it’s not good enough to be Penalties for breaches of REMIT apply to ‘pretty sure’. If there is any doubt, advice individuals as well as companies. In September should be sought swiftly from colleagues 2020, SSE was penalised for an historical breach in Legal Services and Regulation, a note of of wholesale energy market regulations relating the decision made, and any update agreed to the timing of disclosure of capacity availability made as soon as possible. at Fiddlers Ferry power station in 2016. SSE did not benefit from the timing of the disclosure but Ofgem ruled that the Company did not act in an “effective and timely” way and it imposed a RESOURCES AVAILABLE substantial fine. • Group Disclosure and Share Dealing Who does REMIT apply to? Policy REMIT rules apply to people who are involved in • REMIT e-learning training module transactions of wholesale energy products and anyone who has access to inside information Contact that might affect the market, including details • Queries regarding REMIT should be of power plant outages. Training is mandatory directed to SSE’s Regulation team at for anyone at SSE whose role falls within these [email protected]. categories. If you are unsure about your REMIT responsibilities or training requirements, you should speak to your line manager.

What are the right behaviours? For SSE’s businesses participating in wholesale energy markets this means, amongst other things, ensuring effective identification, handling control and timely public disclosure of information by market participants to ensure market integrity.

23 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 24 TRADING FAIRLY AND TRANSPARENTLY MEETING DISCLOSURE AND PREVENTING CORRUPTION SHARE DEALING OBLIGATIONS AND FINANCIAL CRIME

Treat all investors equally Crime won’t pay What is disclosure and share dealing? obligations as a listed company. This supports the What is corruption and financial crime? DILEMMA SSE is listed on the London Stock Exchange, fundamental principle that all investors should be Corruption involves dishonest or illegal behaviour, treated equally. which means that people can trade in its shares. deception and/or concealment (whether for I have noticed something unusual in the SSE therefore has a related requirement to make personal gain or perceived company benefit) and way a business energy customer in running Occasionally, some of us may receive inside certain types of information public, within specific can include, but is not limited to, acts of financial their account. The customer is building up information about SSE that is not available to the timeframes, and in a particular way so that all crime, internal or external fraud, theft, bribery, a large credit balance and asking for it to be general public and could influence an investor to shareholders can assess their investment on mis-reporting, deception or misappropriation. reimbursed to another bank account. This buy, sell or hold shares, and if disclosed, may lead equal terms. Bribery is where a financial or other advantage is customer has been with SSE for a long time to a significant up or down movement in the price given or received to improperly induce people and is a valued customer. Is it alright to go of SSE’s shares. As employees we must not be The highest class of confidential information that to do things or ‘reward’ them for already having ahead and reimburse the credit balance to involved in any dealing in SSE shares while we have a company can hold is called inside information. done so. the bank account that the customer has access to this information; we must not disclose it; SSE must have in place processes to prevent requested? inappropriate use of inside information when it nor encourage anyone else to deal in shares based Why is this important for business ethics? knows individuals have access to it. Inappropriate on such information. These actions could result in Individuals and companies can be held legally In the first instance you should raise your use can constitute an illegal act and include telling an individual breaking the law and committing a accountable for bribing other individuals or concerns through the correct channels. The other people of the inside information and dealing criminal act with severe consequences. organisations. We should ensure our decisions pattern of payments that you describe is based upon it. Examples of inside information and actions are lawful and ethical, based on typical of that used by money launderers. It is could include: annual or half-year results; major DILEMMA the right thing to do for the Company and our important to remember not to discuss your deals to buy or sell a business; changes to the colleagues, rather than for personal gain. concerns with the customer, nor with any Board; and major contracts awarded. I’m working on a really important project colleagues who do not need to know about where SSE might invest a lot of money. What are the right behaviours? this, as this could constitute “tipping off” Some of us will receive different classes of It’s very exciting, can I discuss it with It’s in all our interests that SSE has an established which is, in itself, an offence. confidential information about SSE through the colleagues and friends? reputation for ethical and lawful behaviour and work that we do and in some instances on a for financial integrity in all aspects of our business. Any information that could have an impact regular basis. When this is the case, an individual We all have to maintain a culture whereby bribery, RESOURCES AVAILABLE may be told that they are an Insider or Restricted on SSE’s share price must be kept strictly corruption or financial crime is unacceptable. Person in relation to SSE and that they are required confidential, additionally, as part of this • Group Corruption and Financial Crime to understand the rules within SSE’s Share Dealing project you are likely to be on an ‘insider As hospitality and/or gifts received could be Prevention Policy Procedure. These include asking permission to list’ or ‘restricted list’. This means you must perceived as a form of bribery, clear principles • Financial Crime Guide deal in SSE shares and a strict prohibition against not discuss the project with anyone who should be followed when deciding whether to • Financial Crime Framework dealing at certain times during the year. is not on that list alongside you, and you accept or offer hospitality or gifts. • E-learning modules: must seek permission before dealing in - Fraud awareness Why is this important for business ethics? SSE shares. Dealing may not be permitted - Bribery and Anti-Corruption The value people attribute to SSE’s shares will be depending on the status of the project. - Anti-Money Laundering and influenced by the information they have about the Financial Sanctions Company. For this reason, in SSE we are strongly committed to complying with our obligations as a RESOURCES AVAILABLE Contact listed company under the Market Abuse Regulation • Contact your Business Anti-Financial (MAR) and the Financial Conduct Authority’s rules. • Group Disclosure and Share Dealing Crime Officer, the Group Corporate Policy Anti-Financial Crime Officer or the

Group Compliance Team. What are the right behaviours? Contact • CorporateAnti-FinancialCrime At SSE, we need to ensure the timely, fair and • Company Secretary – call: @sse.com proper disclosure of information using the 01738 455113 correct channels in line with the applicable legal

25 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 26 TRADING FAIRLY AND TRANSPARENTLY PROCURING GOODS AVOIDING CONFLICTS AND SERVICES RESPONSIBLY OF INTEREST

Buy in the right way Looking after our personal reputation What is responsible procurement? What are conflicts of interest? DILEMMA DILEMMA At SSE, our responsibilities to our customers A conflict of interest is a situation at work in and stakeholders do not stop with our direct which someone is in a position to derive personal I work in a small depot and the cleaning I work in renewables and my husband operations. We have a large and complex supply benefit for themselves or someone or something services provided through the company part owns a small company that is bidding chain and by setting standards of conduct with associated with them (such as a family member are very poor. I know we can hire a small for forestry work on a new wind farm our suppliers and contractors positive outcomes or friend or other organisation) from actions they local company to do the cleaning for site with SSE. Does that form a conflict that support SSE’s position as a sustainable take or decisions they make at work. Examples much less cost and better quality and we of interest? company can be achieved. can include recruiting or contracting a close can pay for it through the depot. Can I hire friend or family member, having a second job them? It might do. It depends if you have Why is this important for business ethics? or holding a financial interest in a supplier or access to knowledge that could place There are very good reasons why SSE We expect business to be conducted ethically contractor. your husband’s firm at an advantage, or, procures goods and services centrally. It and sustainably. That includes complying with the even more seriously, could allow you to means we can insist on high standards obligations that arise from the EU Procurement Why is this important for business ethics? influence the process. In this case, you on things like health and safety and we Directives: transparency; non-discrimination; When a conflict of interest arises, it can cast should tell your line manager immediately can be sure that the business employed is equal treatment; mutual recognition; and doubt on our integrity and ability to make – it is better to be safe than sorry. If it is a legitimate. In this case, the fact that there proportionality. objective and unbiased decisions. Sometimes conflict, it is likely you will be prevented are problems with the current cleaning a perceived conflict of interest can be equally from getting involved in any decisions that services should be raised with the contract We depend on the goods and services damaging. relate to this or other projects that may be manager – we should give the existing provided by suppliers and contractors to fulfil linked to your husband’s business, both company a chance to improve. If through our responsibilities as a company. We expect What are the right behaviours? now and in the future. suppliers and contractors to provide those goods a managed improvement plan, they fail We must avoid situations where our personal and services on time and on budget. In turn, we to improve, then a new process can be interest could be in conflict with those of SSE. have a responsibility to pay on time and within established to appoint a new supplier fairly. We all have a responsibility to inform our the terms agreed. We want to encourage local suppliers, and manager of a potential or actual conflict as RESOURCES AVAILABLE the local company you mention could be soon as we become aware of it. • Group Corruption and Financial What are the right behaviours? encouraged to participate in the process. Crime Prevention Policy SSE’s suppliers and contractors are expected to meet the principles outlined in the Responsible Contact Procurement Charter. This means as a minimum RESOURCES AVAILABLE • Contact your line manager with any complying with local laws and regulations and • Group Procurement Policy concerns, which can be escalated respecting internationally-recognised human • Responsible Procurement Charter to your your Business Anti-Financial and labour rights and ensuring that there is • Procurement: Code of Practice Crime Officer. fairness and respect on the part of suppliers and • Procurement and Commercial contractors towards their own employees and Engagement Portal other stakeholders. Contact At SSE, we will always work to pay suppliers • Email: [email protected] and contractors on time and within the • For concerns around breaches of the terms agreed at the start of the contract and Responsible Procurement Charter – without attempting to change payment terms email: [email protected] retrospectively. We also help them play their part • For issues relating to the payment of in the payment process, including ensuring they the Living Wage in our supply chain – have a purchase order number which is quoted email: [email protected] on all invoices and other communications.

27 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 28 PART 3: WORKING TOGETHER

Valuing the people we work with At SSE, we work together, respect each other and make a difference.

Part 3 covers: • Human rights and modern slavery • Inclusion and diversity • Bullying, harassment and discrimination • Paying the Living Wage

29 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 30 WORKING TOGETHER HUMAN RIGHTS AND INCLUSION MODERN SLAVERY AND DIVERSITY

A zero-tolerance approach Encouraging difference What are human rights and modern slavery? What is inclusion and diversity? DILEMMA DILEMMA Human rights are rights inherent to all human Across SSE, we are focused on building an beings, whatever our nationality, place of I work for SSE Thermal and regularly visit inclusive and diverse team of people with a Your colleague has started to work residence, gender, national or ethnic origin, one of our major construction sites. I shared commitment to contributing positively reduced hours to care for their disabled sexual orientation, colour or religion. Human have noticed many new labourers on site, to a great place to work, an ethical business and child and you notice that a senior manager rights abuses and examples of modern slavery apparently working for a tier 3 contractor, a successful company. This means employing has made some comments about their includes forced labour, servitude, slavery, human and they appear to speak only to their people with a balance of skills, knowledge, commitment to work and has stopped trafficking, debt bondage, forced or servile supervisor, they avoid eye contact with experience, education and industry backgrounds inviting them to regular meetings. marriage, descent-based slavery and child labour. the other contractors on site and they and respecting and supporting all of the different keep themselves to themselves. Could characteristics that are protected under equality Even though you are not personally Why is this important for business ethics? anything be wrong? legislation, complying with the spirit as well as the affected, you can still raise your concerns An organisation built on a foundation of abusing letter of the law. with the people involved or with your line the fundamental rights of the people who work Without knowing more, it is difficult to be manager. If you don’t feel comfortable with for it will not be successful. Protecting people certain, but this might be an example of Why is this important for business ethics? this, you can raise it with AskHR or call the from these risks and those who seek to exploit forced or bonded labour (also known as A diverse workforce means there is a breadth Speak Up helpline. Often, situations like this them must be a cornerstone of any sustainable modern slavery). This is more common in of difference that supports our ability to can be resolved informally through positive business. the UK and Ireland than you might think. better reflect the customers we serve and the communication and education. So you are right to identify the risk, and stakeholders we depend on and to achieve all of What are the right behaviours? when you are on site, the best thing to do our business goals. There are absolutely no circumstances where is to sensitively ask questions of the site RESOURCES AVAILABLE human rights abuses or modern slavery is manager about the company employed, An inclusive workplace makes sure we are fit acceptable. We respect recognised international and if there are any concerns. The first for the future by becoming attractive to the human and labour rights and have a zero- entire available workforce, regardless of their • SSE Employment Policy priority is to make sure the labourers • SSE Inclusion and Diversity tolerance stance on modern slavery. are safe and if there are concerns, then background or characteristics protected under It is our responsibility to understand the risks equalities legislation; allowing them to develop Sharepoint site the issue should be escalated by the site • Access the HR Hub from ssenet of human rights abuses within our own manager to Group Security. meaningful careers in an environment that is business and supply chain and ensure ongoing personally supportive and professionally fulfilling. management of those risks. We are guided by the Contact principles and standards set out by a number of What are the right behaviours? • Ask HR can be contacted by calling international bodies, such as the United Nations RESOURCES AVAILABLE • We respect and actively seek the views of 0345 072 1942 or emailing and International Labour Organisation. everyone and listen to what everyone has [email protected] • Group Human Rights Policy to say. Any concerns regarding human rights and • SSE’s Modern Slavery Statement • We are self-aware and look to understand modern slavery within SSE’s direct operations • Responsible Procurement Charter differences so that we can behave in an or supply chain activity should be immediately inclusive way that respects others. reported through the appropriate channels. Contact • We look to recruit from all areas of society • Suspected instances of human rights and are actively engaged in changing abuses or modern slavery should society’s perception of working in the be reported to the police in the first energy industry. instance, as well as to the Group • We do our best to create an environment Investigations and Security Team – where everyone feels supported, regardless email: [email protected] of their difference.

31 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 32 WORKING TOGETHER BULLYING, HARASSMENT PAYING THE AND DISCRIMINATION LIVING WAGE

Treating everyone fairly Fair pay for fair work What is bullying, harassment What is the Living Wage? DILEMMA DILEMMA and discrimination? SSE has been an accredited Living Wage Bullying, harassment and discrimination relates to I’ve just joined a new team with a very employer in the UK since 2013 and has paid its What should I do if I’m not receiving the treating people in a negative way. Discrimination aggressive working culture. One of the Irish employees a Living Wage since 2016. The Living Wage? specifically refers to treating people differently for members of the team is constantly picked Living Wage is a voluntary rate calculated using a a specific reason, for example because of their on, and I’m scared they will pick on me robust and independent methodology as a rate If you, or anyone you know who works age, disability, gender, marital status, race, religion next. What should I do? someone needs to earn to live a decent life. It is directly for SSE, or is contracted regularly or belief, sexual orientation or their pregnancy different to the Government’s National Minimum to SSE in the UK (other than trainees), is and maternity. You have the right to challenge Wage and its enhanced rate for the over-25s, receiving a rate of pay that is less than unacceptable behaviour directly with the called the national living wage. the Living Wage, you should immediately Why is this important for business ethics? people involved or with your line manager. let the team at SSE know by emailing We must make sure our workplaces are free from If you don’t feel comfortable with this, you Why is this important for business ethics? [email protected]. You can also call the discrimination, bullying and harassment so we can raise it with the local HR manager, or As well as being a decision which is good for Speak Up hotline. promote an environment where our employees call the Speak Up helpline. business, we believe paying everyone that works treat everyone as they would like to be treated for us – including those that work on our behalf – at least a rate on which they can live a decent life themselves. That means we must treat each RESOURCES AVAILABLE other, including people we work with from other is the right thing to do. RESOURCES AVAILABLE organisations, with fairness, dignity, respect and • Visit www.livingwage.org.uk for open-ness. • Group Employment Policy What are the right behaviours? information about the real Living • SSE Grievance Procedure Everyone who works for SSE directly is paid at Wage. What are the right behaviours? • Access the HR Hub from ssenet least the Living Wage, with annual increases • SSE Living Wage in the Supply Chain At SSE we do not tolerate any form of harassment implemented from 1 April each year. Procedure that fail to respect the rights of others. Contact • Ask HR can be contacted by calling Our suppliers should be aware of SSE’s Contact It’s the responsibility of all of us who work for 0345 072 1942 or emailing commitment to paying the Living Wage to people • For issues around the Living Wage SSE to provide a safe, engaging and inclusive [email protected] working regularly on its sites in the UK, and have for direct employees – email: working environment, and to observe the clear a responsibility to ensure these workers receive at [email protected] standards of conduct that apply to every one of least the real Living Wage while working on behalf • For issues around the Living Wage us employed by SSE – up to, and including, the of SSE. in our supply chain – email: Chief Executive, as well all other members of the [email protected] Board.

Anyone experiencing harassment at work should raise it with their line manager, but if that is not appropriate Speak Up and call Safecall. Anyone speaking up can expect their issue to be treated sensitively and, where appropriate, offered counselling.

33 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 34 PART 4: ENGAGING WITH STAKEHOLDERS

Being open and accountable SSE’s stakeholders are people, communities and organisations with an interest or concern in SSE’s purpose, strategy, operations and actions and who may be affected by them. To do business ethically, we aim to go further and pro-actively engage with stakeholders, who are critical to our success, in an open and accountable way. Our key stakeholder groups include: energy customers; shareholders and lenders; government and regulators; suppliers, contractors and partners; NGOs, communities and civil society; and employees.

Part 4 covers: • Providing accurate information • Engaging with politicians and regulators • Talking to media and communications • Ensuring transparency

35 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 36 ENGAGING WITH STAKEHOLDERS PROVIDING ACCURATE ENGAGING WITH INFORMATION POLITICIANS AND REGULATORS

Keep good records Openness and transparency What is accurate information? What is political and regulatory engagement? DILEMMA DILEMMA Accurate information is about keeping a correct Many of us at SSE are required to engage with and complete record of operational and I helped put together the response to a regulators, non-departmental public bodies and Our colleague knows the local MP and financial information and decisions, so that our request for information from one or our institutions of government to do our jobs. has asked us to lay on a visit so the MP key stakeholders are able to rely on what we regulators. I’ve since found a couple of can meet people and promote SSE on the at SSE say. It’s about being able to respond in a minor errors that I don’t think anyone Why is this important for business ethics? back of the visit. This seems like a good responsible way to requests for information from else will notice. What should I do? We understand the importance of freedom of idea. Is it OK to arrange the visit? customers, regulators, shareholders and all other information and the requirement for transparency stakeholders. Highlight immediately to your line manager in relation to companies’ dealings with It’s generally a good thing to welcome MPs, and any other colleagues involved that you government and regulators. and other elected representatives across Why is it important for business ethics? have identified the errors. As individuals, the UK and Ireland, on to SSE sites provided Customers, regulators and shareholders all make we can’t judge by ourselves whether they What are the right behaviours? the visits are safe and don’t interrupt decisions and take action based on information are minor or not, and as a company we At SSE we aim to maintain the highest standards essential, time-sensitive operations. But provided to them by us at SSE, so we must make have to make sure we comply fully and of probity in our dealings. We aim to work in line all visits should be organised via SSE’s every effort to ensure that information is accurate. accurately with requests for information with relevant best practice and, where applicable, Corporate Affairs teams, with a good If we accidentally or deliberately provide incorrect from regulators. Highlighting the errors regulation and legislation, and ensure any record of the visit and the issues discussed, or incomplete information, it could have a will enable that to be done. representations made by us are fair and balanced maintained. So any approach from an MP negative impact on those and other stakeholders and represent the position truthfully and honestly. or other elected representative should go – and on us at SSE. The negative impact could be straight to the Corporate Affairs team. a loss of confidence on the part of stakeholders We remain neutral towards political parties and like shareholders and customers or penalties RESOURCES AVAILABLE do not contribute to political parties or political imposed by regulators. It will make people less campaigns; and we avoid doing anything that • Group Employment Policy RESOURCES AVAILABLE likely to want to do business with SSE. could be construed in any way as solicitation of • SSE Grievance Procedure favour. • Access the HR Hub from ssenet • Group Political and Regulatory What are the right behaviours? Engagement Policy • Understand the operational, financial Contact and other information that needs to be • Ask HR can be contacted by calling Contact maintained to be provided to stakeholders. 0345 072 1942 or emailing • Email: [email protected] • Keep a record of the reasons for important [email protected] decisions affecting stakeholders. • Make sure that there are good processes in place for collecting, checking and maintaining that information, in a secure way. • Co-operate constructively with any internal and external reviews, audits and investigations. • Highlight immediately any inaccuracies or incompleteness in records. • Support colleagues who highlight issues with information accuracy – and don’t commission or assist with any ‘cover-up’.

37 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 38 ENGAGING WITH STAKEHOLDERS TALKING TO MEDIA ENSURING AND COMMUNICATING TRANSPARENCY

Representing the company and ourselves Paying a fair share What is media and communications? What is tax transparency? DILEMMA DILEMMA There are many different methods of SSE is subject to requirements around tax communication. Social media platforms include I’m interested in discussions around reporting under UK Company Law and fully A supplier has asked me to pay an invoice channels such as Facebook, Twitter, YouTube, climate change and spend a lot of time discloses its tax affairs in its Annual Report they have issued to us that is in another Yammer and LinkedIn, while other types of media on social media commenting on Twitter, according to accounting standards and the company’s name, to reduce their tax include broadcast, electronic and print. These blogs and online news sites. My personal enhanced disclosure requirements of the Fair liabilities. Is that okay? are all used by SSE to communicate, discuss and views don’t always align with SSE’s. is this Tax Mark. SSE has been Fair Tax Mark accredited share information and as a means of engaging still OK? since 2014 – an independent third-party Under the Corporate Criminal Offence Act with stakeholders. accreditation that demonstrates SSE pays the 2017, it is illegal for a company to facilitate Anything you do or say on social media right amount of corporation tax, in the right tax evasion. Knowingly paying an incorrect Why is this important for business ethics? has to be in a personal capacity. At place, at the right time. invoice could assist in facilitating tax Effective external and internal communications the same time, as an employee of the evasion. Taking that action could therefore are essential to the success of any organisation Company, anything you say about SSE Why is this important for business ethics? result in SSE being prosecuted. that operates in the public eye and has a wide on social media has to be consistent with SSE believes that tax conduct is linked to trust range of stakeholders. We want to ensure that all the obligations and rules we have as a in big business and that openness about our tax the information we disclose is timely, accurate, company. It’s therefore wise to err on the affairs is essential if we are to be a company that RESOURCES AVAILABLE comprehensive and relevant. side of caution. does business ethically and that people can trust. Clear and transparent disclosure is key for SSE’s The lines between our personal lives and work stakeholders to understand the taxes that it pays • Group Taxation Policy lives can easily become blurred when using and its approach to tax practices. • Talking Tax booklet social media in particular. It is important that, RESOURCES AVAILABLE when representing the Company, we conduct What are the right behaviours? Contact • Media Procedure ourselves in a way that maintains SSE’s values and We take pride in paying our fair share of tax. Our • Head of Tax • Social Media Procedure high standards. Social media posts can be used primary objective from a tax perspective is to be by our stakeholders or the public for positive or compliant with all tax legislation requirements. Contact negative reasons. • Email: [email protected] That’s why we operate within both the letter and What are the right behaviours? the spirit of the law at all times and don’t use It is important that we do not use the Company’s artificial tax avoidance schemes or tax havens to external communication platforms unless we’ve reduce the Company’s tax liabilities. But we do been trained and have the right approval. If you make timely and accurate returns which reflect are considering using social media or other our fiscal obligations to government. media channels in a business capacity, or have been contacted by someone in the media At the same time, we do not help our customers, such as a journalist, you should seek advice and suppliers and anyone else we work with to approval from the Media team first. fraudulently underpay, or not pay, tax.

When using social media in a personal capacity, always ensure that it is clear that your comments are your own and not those of SSE. You should always be careful when posting on social media, and speak to the Media team if you are unsure about your own posts or those of a colleague.

39 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 40 DOING THE RIGHT THING KNOWING WHO TO SPEAK TO

Useful contacts Safecall Cyber Risk and Information Security team SSE Human Resources team SSE Corporate Affairs team Safecall is an independent first point of contact For general queries or advice relating to Your business HR contact can help you with Any social media, media or press enquiries for people who feel they cannot raise concerns information and cyber risk, contact the team any HR issues, including advice on equalities or should be directed to the Media team in about wrongdoing via their line manager or using the Employee Emergency number above. harassment. If you don’t know who that is, Ask Corporate Affairs. other internal procedures. HR can be contacted by calling 0345 072 1942 Email: [email protected] or emailing [email protected] Email: [email protected] Call 0800 915 1571 in the UK or 1 800 812 740 in Ireland. SSE Legal team SSE Procurement team Any queries relating to SSE’s political activities or Any questions relating to any of the laws For any general questions or queries relating to internal communications should be directed to Report online at www.safecall.co.uk/report or referred to in this guide can be directed to SSE’s the procurement of goods and services, email: SSE’s Corporate Affairs team. email [email protected] Legal team. That includes questions about [email protected] Competition Law, data protection and bribery Email: [email protected] SSE Security and Investigations team and corruption. If you have concerns around breaches of the The Security and Investigations team are always Responsible Procurement Charter, email: SSE Sustainability team available to provide support if you suspect Email: [email protected] [email protected] The Sustainability team should be contacted or know about unethical behaviour in the if none of the other contact details above are Company or our supply chain. You can SSE Company Secretarial team Any questions relating to the payment of the appropriate for the issue you need resolved. confidentially contact them with your concerns. Questions relating to share dealing should be Living Wage in our supply chain should be sent directed toward the Company Secretarial team. to: [email protected] Email: [email protected] Email: [email protected] Call: 01738 455113

Employee Emergency number SSE Business Separation team DOING BUSINESS ETHICALLY To report a significant safety, health or For business separation breaches email environment incident; actual or suspected Business Separation Compliance Officer. This guide summarises for all of us at SSE what it means to engage with stakeholders, criminal activity or an IT information or cyber work together, trade fairly and transparently and stay safe and secure. If we do these security incident. Email: [email protected] things, we are doing business ethically; and if we do business ethically we will be in a much stronger position to create value for shareholders and society. Call 0800 107 3207 in the UK or 1 800 927 219 Or if Forbury Assets Limited then: in Ireland. Forbury Assets Compliance Officer: Doing business ethically – doing the right thing – means we are able to enjoy our jobs, [email protected] sleep soundly at night, and make a positive contribution to the economy and society. So SSE Safety, Health and Environment team while doing business ethically is great for SSE; it’s even better for each of us personally The SHE Team are the first port of call for any SSE Regulation team and for the people who depend on us. general questions or concerns you may Any regulatory questions, including queries have about the management of safety, any relating to REMIT should be directed to SSE’s issues relating to environmental protection or Regulation team. the promotion of healthy working lives. Email: [email protected] Incidents must be reported on the Employee Emergency number.

Email [email protected]

41 || SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT SSE PLC GUIDE TO ETHICAL BUSINESS CONDUCT || 42 SSE plc Corporate Affairs Inveralmond House 200 Dunkeld Road Perth PH1 3AQ UK

Registered in Scotland No. 117119

If you have any comments or queries about this guide, please get in touch with the SSE Sustainability Team at [email protected]

Print copies of this guide are available from SSE Print Management Centre Published September 2020